NC governor race request for expedited hearing filed with the State Board of Elections, Recount of Durham County early vote, Attorney Thomas Stark formal appeal, Malfunctions and irregularities, Remove the votes of persons ineligible

“Durham historically hasn’t figured out how to carry out an election properly.”…Superior Court Judge Donald Stephens

“Durham County is widely considered to be the most liberal county in NC.”…Citizen Wells

“We control life, Winston, at all its levels. You are imagining that there is something called human nature which will be outraged by what we do and will turn against us. But we create human nature. Men are infinitely malleable.”…George Orwell, “1984″

From Pat McCrory for Governor November 26, 2016.

“Request for expedited hearing filed with the State Board of Elections

Appeal requests the State Board expeditiously call for a recount of the Durham County early vote data tabulated on election night”

“Today, attorney and registered Durham County voter Thomas Stark filed a formal appeal with the State Board of Elections in relation to the ‘malfeasance’ in tabulating approximately 90,000 ballots that were reported just before midnight on Election Day. The original complaint reasonably demands the County Board of Elections conduct a recount of the original paper ballots before the county’s canvass date. The county denied this request and the Pat McCrory Committee concurs in a call for an expedited appeal of the protest for a full recount of the Durham county early vote ballots. This reasonable request will provide confidence and clarity in the Durham results for the voters of North Carolina. Upon completion of this recount, we can better asses next steps.

“It was concerning to learn that the Durham County Board decided to not approve attorney Tom Stark’s protest to recount the early vote totals from election night. The malfunctions and irregularities in Durham have been extremely troubling to this campaign and the people of North Carolina, and the State Board confirmed several errors. We are now left with no other position but to request the State Board of Elections expeditiously order a full recount of Durham county early vote totals. Once this occurs, we can all move towards a conclusion of this process,” said Russell Peck, campaign manager for the Pat McCrory Committee.

As earlier reported by ABC11, their has been a long history of voting problems in Durham County. In the 2016 general election, electronic errors, glitches and untrained staff caused major problems that received bipartisan scorn. Superior Court Judge Donald Stephens even stated in a recent hearing on the problems, “Durham historically hasn’t figured out how to carry out an election properly.”

During the March 15 primary election, the Durham County Board of Elections mishandled roughly 1,900 provisional ballots forcing the state to allow eligible voters to recast their ballots months later. It was also recently reported that the state board of elections turned over their completed investigation to investigators who are now looking into whether crimes were committed in this case, as election officials said the wrong vote count was accurate and some votes may have been counted twice.

If a Durham recount provides the same results as earlier posted, the McCrory Committee will be prepared to withdraw its statewide recount request in the Governors race.”

“It doesn’t matter what the friggin legal and ethics people say, we need to win this motherf**cker”…Scott Foval, Project Veritas video

“As I stated earlier, this is not about sex or private conduct, it is about multiple obstructions of justice, perjury, false and misleading statements, witness tamperings and abuses of power, all committed or orchestrated by the President of the United States.”…David Schippers report to House Judiciary Committee

“Billy and Hillary Clinton continue to be lying, cheating, manipulative, scratching, clawing, ruthlessly aggressive, insatiably ambitious politicians who are giving public service a bad name – and nothing about them has changed in the past forty-plus years, except that they have deluded more and more people,”…Dolly Kyle Browning

*** Update below ***

Ellen Weintraub, formerly of Perkins Coie, still a member of FEC?

If so, this will go nowhere.

More on this later.

James O’Keefe of Project Veritas, has filed a complaint with the FEC.

From the complaint.

“Journalists with Project Veritas Action Fund (“PVA”) have uncovered a criminal conspiracy where, in the words of Scott Foval, “The way it works is: The [HFA] campaign pays DNC, DNC pays Democracy Partners, Democracy Partners pays The Foval Group, The Foval Group goes and executes the … on the ground.” This has been done in a manner to evade federal election law and violating coordinated expenditures rules.”

Forget for a moment the other bias and chicanery associated with the FEC ( hard drive from IRS, etc. )

To the best of my knowledge, the FEC is the only federal government agency since 2008 to address the natural born citizen requirement for presidency in the US Constitution.

In Hassan v FEC they established that just being a US citizen is not enough. Hassan is a naturalized citizen and not eligible for matching federal funds.

They did not prohibit his running since they are only responsible for the monetary aspect.

What is significant about Ellen Weintraub being a commissioner?

1. She is a former Perkins Coie employee. You know, the law firm that made hundreds of thousands of dollars off of the Obama campaign, helped Obama keep records hidden via attorney Robert Bauer ( husband of Anita Dunn ) and requested an advisory opinion from the FEC in 2007 regarding Obama’s matching fund options.

2. Weintraub was a FEC commissioner in 2007 when the FEC provided the advisory opinion.

3. Weintraub was a commissioner in 2008 when the FEC rejected Philip J Berg’s plea for a ruling on Obama’s natural born citizen status.

4. Weintraub has been a commissioner since December 2002 despite her tenure of 6 years being exceeded.

5. Weintraub is a liberal Democrat.

6. Weintraub’s participation as a commissioner with the Perkins Coie ties to Obama is troubling.

7. Numerous articles have been written about Obama not replacing commissioners on the FEC, despite their terms running out, but I have found none other than my own questioning Ellen Weintraub being retained.

8. Why did Wikipedia make it appear like Weintraub began as a commissioner in 2008?”

“Obama hired Robert Creamer, a specialist in voter fraud, in 2007 to train supporters at “Camp Obama” in door-to-door canvassing. That is a technique for gathering data for voter fraud.”…Citizen Wells

“North Carolina is the latest state featured by Project Veritas in its series on how America’s electoral system is extremely vulnerable to voter fraud. During last week’s North Carolina primary, James O’Keefe and his colleagues demonstrated how easy it is to obtain ballots even if the person has publicly professed not to be a U.S. citizen.”
O’Keefe also tells WND about his group’s visit to the University of North Carolina, where a dean and a program director laugh off confessions of voter fraud and even seem to encourage it. Yet a day later, both officials tell conservatives that voter fraud never happens.”…WND May 15, 2012

“It doesn’t matter what the friggin legal and ethics people say, we need to win this motherf**cker”…Scott Foval, Project Veritas video

Obama was heavily involved with ACORN before running for the presidency.

James O’Keefe, a few years ago, exposed ACORN’s involvement in voter fraud and subsequently their funding was cut off by congress.

Obama hired Robert Creamer, a specialist in voter fraud, in 2007 to train supporters at “Camp Obama” in door-to-door canvassing. That is a technique for gathering data for voter fraud. This is explained in the video below.

Robert Creamer resigned today from Democracy Partners after being outted in the video.

Robert Creamer visited the White House 342 times since 2009 and Obama 47 times.

Robert Creamer and Democracy Partners worked closely with Scott Foval and People for the American Way as well as the Hillary Campaign and DNC.

Scott Foval was fired yesterday.

Scott Foval, Deputy Political Director at People for the American Way explains canvassing.

“Now, if we just had the canvassers logging the homes, they don’t even have to know why they’re doing it. Just put a mark on it. And say, this address… we have moved, but moves could mean someone else moved in. And then take that data, and flip it out, and you give it to people, and you have people go vote in it. That’s brilliant. I love it.”

From Chicago Magazine November 29, 2007.

“Since June, Barack Obama’s presidential campaign has been gathering volunteers for its two-day “Camp Obama” seminars, where supporters learn techniques for phone banking, door-to-door canvassing, and other nuts-and-bolts campaign activities. The sessions are taught by campaign staffers, as well as by top Democratic operatives. One Camp Obama instructor has drawn partisan criticism, however. Robert Creamer, the former director of the state’s largest consumer advocacy organization, Citizen Action of Illinois, who in 2005 was sentenced to five months in prison after pleading guilty to bank fraud and withholding taxes while heading the group, has run sessions for Obama’s campers. Creamer’s role came to light after his “information-packed presentation” was described in a Vermont-based volunteer’s blog on Obama’s Web site.

An Obama campaign official says the campaign welcomed Creamer’s expertise because he is one of the most experienced organizers in Illinois. (Creamer’s wife, U.S. Rep. Jan Schakowsky, is also a longtime Obama booster.) But conservative columnist and radio host Tom Roeser and other bloggers have argued that Creamer’s involvement undercuts Obama’s clean-cut, reform-minded public image. “Creamer’s being hired by the Obama campaign to instruct interns and volunteers in political organizing, abuses of which sent him to jail, is ironic,” as Roeser put it in his blog. Calls to Creamer’s office were not returned.”

“Concerns about high voter turnout and the inability of the precincts to adequately handle the number of participants and monitor the election process are rampant. On the night of the caucus itself, the Clinton Campaign brought many instances of these irregularities to the attention of the State Party. The
campaign received in excess of 2,000 complaints of rules violations, indicating widespread violations of the Party’s rules”…Dr. Lynette Long, March 4, 2008, Texas Democratic Primary

“It doesn’t matter what the friggin legal and ethics people say, we need to win this motherf**cker”…Scott Foval, Project Veritas video

“We control life, Winston, at all its levels. You are imagining that there is something called human nature which will be outraged by what we do and will turn against us. But we create human nature. Men are infinitely malleable.”…George Orwell, “1984″

“With opinion polls showing him falling further back in recent days against his White House rival, Democrat Hillary Clinton, Trump has intensified his allegations, although numerous studies have shown voter fraud in U.S. elections is rare.

Obama was asked about Trump’s assertions on Tuesday at a joint news conference in the White House Rose Garden following meetings with Italian Prime Minister Matteo Renzi.

He responded with a blistering attack on the Republican candidate, noting that U.S. elections are run and monitored by local officials, who may well be appointed by Republican governors of states, and saying that cases of significant voter fraud were not to be found in American elections.

Obama said there was “no serious” person who would suggest it was possible to rig American elections, adding, “I’d invite Mr. Trump to stop whining and go try to make his case to get votes.”

Trump has raised the possibility for months of illegal activities that could tarnish the November election result, and he has urged his supporters to show up at polling locations on Election Day. He has sharpened his allegations in recent days, even as Republican lawyers called his assertions unfounded.”

“I first began hearing about ACORN in early 2008. I first began writing about ACORN in August of 2008 when I discovered they were involved in corruption and voter fraud. Then I read some of the analysis of Dr. Lynette Long, who took data from the primaries and caucuses as well as witness stories of ACORN and Obama thugs controlling these processes. I soon discovered that a documentary was being produced of voter fraud. I went to the website and from time to time checked on their progress. Early in 2009, a mutual friend of the producer, Bettina Viviano, introduced me to her and I had several conversations with Bettina about the documentary and the sad state of political affairs in this country.

I spoke to Bettina last night about the status of the documentary. It was on track to be completed next year, but she was receiving a lot of interest due to the recent events exposing ACORN corruption to a wider audience. They may be able to complete the documentary sooner. She also admitted that when she first began investigating voter fraud, she was not aware that ACORN was behind much of it. We also discussed our other projects. It is good to know there are level headed, real Americans in Hollywood.”

“FROM THE TEXAS CONVENTION They shoved Obama signs in Clinton delegates’ faces, three inches from the nose, called them racists, and told my friend that she had to move from her third-row seat in one meeting and go sit in the back. She also said that the proceedings were heavily laced with black power speeches by preachers as well as public officials.” Here are some exerpts from the analysis of data by Dr. Lynette Long:”

Voter Fraud – Temporary Chair packets were released by the election judge prior to 7:00 pm. Sign-in sheets were filled out before 7:00 pm by voters participating in the primary who did not participate in the caucus.

Voter Fraud – Precincts were consolidated for purposes of holding a convention.

Voter Disenfranchisement – Precinct caucuses began before polls closed for the primary.

Voter Fraud – Ineligible participants voted or ineligible delegates were elected, including participants who were not registered voters, participants who did not vote in the primary, and provisional voters whose votes were counted; and no verification was made of the eligibility of participants or delegates.

Voter Fraud – Participants’ names and presidential preference were entered on sign-in sheets by someone other than the eligible individual participants.

Voter Fraud – Results were taken from a head count or hand count rather than the written roll.

Due Process – Delegate votes were not ratified by the precinct convention.

Due Process – Failure to follow Robert’s Rules of Order at the precinct convention.”

On Thursday, May 14, 2015, John Podesta <john.podesta@gmail.com> wrote:

“High importance. I met with Jim and Mike in Denver. They are both old friends of the Clintons and have lots of experience. Mike hosted our Boulder Road Show event. They are reliving the 08 caucuses where they believe the Obama forces flooded the caucuses with ineligible voters. They want to organize lawyers for caucus protection, election protection and to raise hard $. They are not just Colorado focused and have good contacts in the region Mike is likely to talk to WJC about this in the near future. Marlon and Brynne, can you respond to the org chart request and give them some points of contact. Marc can you reach out to them on the lawyer election protection issues. Thanks.”

“It doesn’t matter what the friggin legal and ethics people say, we need to win this motherf**cker”…Scott Foval, Project Veritas video

“As I stated earlier, this is not about sex or private conduct, it is about multiple obstructions of justice, perjury, false and misleading statements, witness tamperings and abuses of power, all committed or orchestrated by the President of the United States.”…David Schippers report to House Judiciary Committee

“Billy and Hillary Clinton continue to be lying, cheating, manipulative, scratching, clawing, ruthlessly aggressive, insatiably ambitious politicians who are giving public service a bad name – and nothing about them has changed in the past forty-plus years, except that they have deluded more and more people,”…Dolly Kyle Browning

Sean Hannity, on his radio show yesterday, interviewed James O’Keefe of Project Veritas.

In this explosive new video from Project Veritas Action, a Democratic dirty tricks operative unwittingly provides a dark money trail to the DNC and Clinton campaign. The video documents violence at Trump rallies that is traced to the Clinton campaign and the DNC through a process called birddogging.

A shady coordinated communications chain between the DNC, Clinton Campaign, Hillary Clinton’s Super PAC (Priorities) and other organizations are revealed. A key Clinton operative is on camera saying, “It doesn’t matter what the friggin’ legal and ethics people say, we need to win this motherfucker.””

“I watched her on countless occasions blatantly lie to the American people and knowingly lie.”…Linda Tripp

“And if all others accepted the lie which the Party imposed
–if all records told the same tale–then the lie passed into
history and became truth. “Who controls the past,” ran the
Party slogan, “controls the future: who controls the present
controls the past.”…George Orwell, “1984″

Citizen Wells analyzed and reported on the alleged Hillary Clinton Dr. Bardack health letter from September 14, 2016 and discovered the following:

The alleged letter was in a PDF file format converted from a Word Document.

It contained the following: “fit to serve as President of the United States.”

The signature did not match the signature on the 2015 letter from Dr. Bardack.

Today is a celebration. The past 5 months (and over a year for my boss) my small team of 3 has been working tirelessly to change Mount Kisco Medical Group to CareMount Medical. We officially rebranded the largest medical group in New York!

I am so proud to have headed the design and production of our website, patient portal, Intranet and all social media outlets. Apologies on the bragging rights but dang- today is freakin cool.

Experience

Strategized and implemented the rebranding of Mount Kisco Medical Group, now CareMount Medical, the largest medical group in Westchester, Putnam, Dutchess, and Ulster counties. Headed the re-skin of the website, employee Intranet, Patient Portal and Social Media platforms. Carried out social media plan for rebanding. Maintain brand awareness and a positive reputation for large medical group with over 500 providers and 40 specialties in 41 locations by updating all social media outreach, managing and updating the website, and posting blogs. Maintaining vertical marketing through Hootesuite, Google Analytics and Facebook Analytics. Staying in constant contact with all doctors within the group by creating and updating physician profiles and arranging media placement to the web. Creating and distributing all promotional flyers, posters and ads for print and web distribution. Coordinating all sponsorship opportunities with local and regional companies.

“After the elections of 1994, and the Democrats’ loss of Congress, I became aware, through my discussions with Ron, that the trade missions were being used as a fundraising tool for the upcoming Clinton-Gore presidential campaign and the Democratic Party. Specifically, Ron told me that domestic companies were being solicited to donate large sums of money in exchange for their selection to participate on trade missions of the Commerce Department. Ron expressed to me his displeasure that the purpose of the Commerce trade missions had been and were being perverted at the direction of The White House.”…Nolanda Hill Affidavit

From Citizen Wells earlier today via the House Judiciary Committee Evidentiary Record of December 1998, we learn:

“In January 1998, Judicial Watch uncovered a witness, Nolanda Butler
Hill, a close confidante and business partner of late Commerce
Secretary Brown, with whom Secretary Brown had shared key details about
the campaign-contributions-for-seats-on-trade-missions scheme, as well
as the Clinton Administration’s efforts to stonewall Judicial Watch’s
lawsuit. Secretary Brown had even shown important documents to Ms. Hill
that detailed this unlawful sale of taxpayer-financed government
services. With Ms. Hill’s uncontroverted testimony providing the
capstone to its investigation, Judicial Watch has proven beyond all
reasonable doubt that not only was the Clinton Administration engaged
in an unlawful scheme to sell seats on Commerce Department trade
missions in exchange for campaign contributions, but that a criminal
cover-up was ordered by President Clinton’s top aides to thwart
Judicial Watch’s Court-ordered investigation and to hide the
culpability of the President, Mrs. Clinton, the Clinton Administration
and the DNC for their use of Commerce Department trade missions as a
political fundraising vehicle.

Ms. Hill testified that then White House Chief of Staff Leon
Panetta and Deputy Chief of Staff John Podesta ordered Commerce
Secretary Brown to defy Court orders and obstruct the Judicial Watch
suit until after the 1996 federal elections. Ms. Hill’s sworn testimony
implicated the President’s top staff members in obstruction of justice.
Ms. Hill also tied the sale of trade mission seats directly to
President Clinton. In both a sworn affidavit and Court testimony, Ms.
Hill explained that:

The First Lady conceived of the idea to sell the
trade mission seats in exchange for political contributions;
The President knew of and approved this scheme;
The Vice President participated in this scheme;
Commerce Secretary Ron Brown helped implement the
illegal fundraising operation out of the Clinton Commerce
Department;

The President’s top fundraisers at the DNC and his
reselection campaign (Marvin Rosen and Terrence McAuliffe)
helped coordinate the selling of these taxpayer resources in
exchange for political contributions;

Presidential Chief of Staff Leon Panetta and Deputy
Chief of Staff John Podesta ordered the cover-up of these
activities; and

The President’s appointees at the Commerce
Department have committed perjury, destroyed and suppressed
evidence, and likely breached our nation’s security.”

From court documents related to the FOIA requests of Judicial Watch to the Commerce Department.

Nolanda Butler Hill affidavit.

“Affidavit of Nolanda Butler Hill

I, Nolanda Butler Hill, being duly sworn, deposes and says:

1. This affidavit is based on my own personal knowledge.

2. I have been a resident of Texas for all of my life and still reside there.

3. Up to the death of Ronald H. Brown, former Secretary of the U.S. Department of Commerce, I was a business partner and/or close personal confidant for over seven years. During this period, I spoke with Ron, as I used to call him, daily, and frequently several times per day. I was thus intimately knowledgeable about both his personal and professional activities. I also had contact with his family, including his son, Michael, and his daughter in law, Tamara, who worked for me for approximately five years.

4. During the course of my relationship with Ron, I was privy to his activities, and the activities of the people who worked or were in contact with him at Commerce, and elsewhere. Since Ron died on April 3, 1996, I have also been in contact and spoken with many persons who worked or were in contact with him at Commerce, and elsewhere.

5. After the elections of 1992, Ron became Secretary of Commerce. Shortly thereafter, Ron decided that he would focus the majority his activities at Commerce on trade missions.

6. In the fall of 1994, I became aware, through Ron and Jim Hackney, Ron’s Counselor at Commerce – with whom I was and remain close – that a group called Judicial Watch filed Freedom of Information Act (FOIA) requests to obtain information and documentation about the trade missions. Both Jim and I encouraged Ron at the time to give due consideration to the seriousness of these FOIA requests, as there were politically sensitive issues surrounding the trade missions.

7. After the elections of 1994, and the Democrats’ loss of Congress, I became aware, through my discussions with Ron, that the trade missions were being used as a fundraising tool for the upcoming Clinton-Gore presidential campaign and the Democratic Party. Specifically, Ron told me that domestic companies were being solicited to donate large sums of money in exchange for their selection to participate on trade missions of the Commerce Department. Ron expressed to me his displeasure that the purpose of the Commerce trade missions had been and were being perverted at the direction of The White House.

8. In the spring of 1995, when this Court ordered production of documents to Judicial Watch, Ron became very concerned and he thus began to discuss with me the strategy of handling the defense of the Judicial Watch lawsuit.

9. I further learned through discussions with Ron that The White House, through Leon Panetta and John Podesta, had instructed him to delay the case by withholding the production of documents prior to the 1996 elections, and to devise a way not to comply with court’s orders.

10. In late fall 1995, after several rulings or statements by this court, Ron himself became more involved in the defense of the case. Specifically, he told me that he had decided to personally review any documents that might be damaging to the Clinton Administration, or in any way be sensitive. Ron told me that he was very worried about the potential damage of the Judicial Watch case to the Clinton Administration.

11. In early 1996, Ron showed me a packet of documents, about 1 inch thick, which he removed from his ostrich skin portfolio. Ron told me that these documents had been provided to him from Commerce Department files as part of the collection efforts to produce documents to Judicial Watch in this case. I reviewed the top five or six documents, which were on Commerce Department letterhead under the signature of Melissa Moss of the Office of Business Liaison. What I reviewed comprised letters of Ms. Moss to trade mission participants, each of which specifically referenced a substantial financial contribution to the Democratic National Committee (DNC). My response was immediate and decisive. I told Ron he must instruct that production of these documents and all responsive documents be immediate and I advised him to mitigate his own damages by releasing Ms. Moss from her duties and admonishing her for using the offices of the Commerce Department for partisan political fundraising.

12. I then saw Ron call the Commerce Department and he spoke with Melissa Moss. He told her that he wanted to meet with her later. I do not know if the meeting ever took place and I had no further discussion with Ron, because of his untimely death, about the documents I had reviewed.

13. I have reviewed the deposition video of Melissa Moss and, based on my knowledge, she has not told the truth in response a number of questions concerning Commerce Department trade missions, as well as other representations she has made under oath.

14. I would like to come forward and tell this court everything I know about the failure to produce documents to Judicial Watch and this court. I am concerned, however, that if I do so, the Clinton Administration, and more particularly its Justice Department, will try to retaliate against me. As a result, I look to this court for guidance on how I can come forward and tell all I know in the interest of justice.

15. Because of a fear for my personal and my family’s well-being and safety, I ask that this affidavit be kept under seal and that a mechanism be set up by the court for me to come forward to tell all I know.

The highest drama in this litigation was supplied by Nolanda
Hill, former business partner and confidante of Secretary Brown:

On January 28, 1998, Hill submitted under seal a sworn
declaration detailing her knowledge of the Department of
Commerce’s handling of Judicial Watch’s FOIA requests,
information that she allegedly obtained through her relationship
with Secretary Brown. Stating that she was concerned about
retaliatory actions by the government, Hill requested that the
Court provide mechanisms for her protection. Pursuant to that
request, the Court ordered that the affidavit be initially kept
under seal and saw to it that her attorney was made aware of the
situation and was willing to represent and protect her interests
in this matter. An evidentiary hearing was then scheduled for
March 23, 1998.

On March 14, 1998, Hill was indicted on criminal charges.
Although an investigation had been underway before Hill offered
to testify in this case, Judicial Watch claims that the
government had represented to Hill that charges would not be
filed, and that the March 14, 1998 indictment was in retaliation
for her cooperation with Judicial Watch.

On March 23, 1998, Hill appeared before this Court and gave
extensive testimony as to her knowledge, gained from
communications with Secretary Brown, relating to this action.6
Upon examination by Mr. Klayman, Hill testified that the
Secretary told her that White House officials had actually
instructed him to delay the production of documents responsive to
Judicial Watch’s requests and to come up with a way to avoid
compliance with this Court’s orders. See Transcript of March 23,
1998 Hearing at 85. Hill vividly recalled the Secretary’s
comment that Leon Panetta (then White House Chief of Staff) had
urged him to “slow pedal” the document search. See id. at 85-86.
According to Hill, this message was conveyed to Secretary Brown
by Panetta and by John Podesta (then White House Deputy Chief of
Staff) on several occasions. See id. at 85-88.

In her role as personal advisor and confidante to Secretary
Brown, Hill allegedly offered to review the most sensitive
documents responsive to Judicial Watch’s request, for the purpose
of finding out precisely what was involved and, according to
Hill, to encourage the Secretary to turn over all responsive
documents. See id. at 88. Hill never did review the material,
however, and she was unable to testify as to whether such a
collection of “the most sensitive” responsive documents was ever
assembled. See id. at 89-90.

Ms. Hill did testify to seeing several unproduced responsive
documents in the Secretary’s possession in 1996, shortly before
the Secretary’s death. According to Hill’s testimony, she met
with Secretary Brown at a hotel early in 1996, and on that
occasion the Secretary showed her a one-inch-thick packet of
documents that he produced from a personal portfolio-type
carrying case. See id. at 38-39. The Secretary told Hill that
the documents had been retrieved from DOC files during the
document search for Judicial Watch’s FOIA requests. See id. at
39. Hill reviewed the top five or six documents, confirming that
they were copies of letters from Melissa Moss to trade mission
participants specifically referencing their donations to the DNC,
clearly responsive to Judicial Watch’s requests. See id. at 40-
41. Needless to say, these documents had not been, and have not
since been, released to the plaintiff. Their current location is
unknown, perhaps unknowable, although Judicial Watch argues that
the evidence supports an inference that the documents were either
destroyed during the flurry of document shredding following the
Secretary’s death, or removed from his office during that same
time period. In any event, Hill’s uncontroverted testimony is
strong evidence that the DOC illegally withheld documents from
Judicial Watch in violation of the FOIA. It is also apparent
that the DOC was aware of this Court’s orders that all responsive
documents be produced, and willfully defied those orders,
according to Ms. Hill’s testimony. This conduct alone would seem
to justify entry of judgment against the DOC, and yet it
simultaneously precludes such judgment until the extent of the
DOC’s unlawful behavior is adequately explored.

Also relevant to this action is the testimony of Ms. Hill
that the deposition of Melissa Moss contained a number of
inaccuracies. See id. at 105 et seq. In addition, revelations
about Moss’s role in the orchestration of the trade missions
casts her deposition testimony in a new light, and also raises
doubts as to how the activities in which she participated could
have produced no documents responsive to Judicial Watch’s
requests. As a whole, the evidence supports an inference that
Moss played an important role in resisting Judicial Watch’s FOIA
requests, and the testimony of Nolanda Hill points in particular
to Moss as directly responsible for knowing violations of this
Court’s orders.7

On April 29, 1998, a superseding indictment was issued
against Ms. Hill. Judicial Watch claims that it was intended as
a further signal to keep quiet.”

“In conclusion, this somewhat tedious narration presents
numerous instances of likely violations of the Freedom of
Information Act and this Court’s orders. On many occasions, the
DOC appears to have engaged in the illegal withholding of
responsive documents, in the removal of such documents from the
DOC, and in the destruction of potentially responsive documents
in the office of the late Secretary Brown and elsewhere, as well
as a great deal of misconduct during the litigation which the
Court leaves for another day’s decision. Upon consideration of
this record, and of the legal issues discussed in Part II, the
Court finds that a new search alone is an insufficient remedy,
and thus the DOC’s motion will be denied, partial summary
judgment will be granted in favor of Judicial Watch ordering the
commencement of the search proposed in the motion, and further
discovery under the supervision of a Magistrate Judge will be
ordered.”